Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:22-cv-07477
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Napa County Superior Court, Judge Hamilton dismissed the prisoner’s nine federal civil-rights cases with prejudice because he could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s nine federal civil-rights cases were dismissed with prejudice. The defendants were state superior courts and officials involved in his criminal prosecution.
What happened
Steven Wayne Bonilla, a state prisoner, filed nine nearly identical federal civil-rights cases against state superior courts and officials involved in his criminal prosecution. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because he was disqualified under federal law and had not shown that he faced an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal rules even if permission to proceed without paying were granted. It dismissed all nine cases with prejudice, closed them, and directed the clerk to return future documents submitted in them without filing them.
Judge Phyllis J. Hamilton issued the order on November 29, 2022.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:22-cv-07477
- Phyllis Hamilton
- Nov. 29, 2022
Background
Steven Wayne Bonilla filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against certain state actors. The opinion identifies Bonilla as a state prisoner and says he is condemned. The defendants included state superior courts and officials involved in his criminal prosecution. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion states that Bonilla had a pending federal petition concerning his imprisonment in this court, with appointed counsel, and was also represented by counsel in state court proceedings concerning his imprisonment.
Reasoning
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore concluded that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate analysis explaining which rule applied to which case or claim.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Case-number scope
The order lists these case numbers: 22-cv-6926-PJH, 22-cv-6974-PJH, 22-cv-7037-PJH, 22-cv-7046-PJH, 22-cv-7396-PJH, 22-cv-7471-PJH, 22-cv-7476-PJH, 22-cv-7477-PJH, and 22-cv-7479-PJH.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.